Legal Opinion

Natkunanathan v. Comm'r

United States Tax Court

Decided February 1, 2010No. 17291-07UnpublishedCited by 1 opinion

R determined a deficiency and an addition to tax under sec. 6651(a)(1), I.R.C., for failure to file on time. In response, P claimed a qualified business stock exclusion under sec. 1202, I.R.C., deductions for uncollected software development invoices under sec. 165, I.R.C., as business losses or, alternatively, under sec. 166, I.R.C., as bad debt losses, and deductions for meals and entertainment, advertisement, rent, and utilities expenses under sec. 162, I.R.C.

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R determined a deficiency and an addition to tax under sec. 6651(a)(1), I.R.C., for failure to file on time. In response, P claimed a qualified business stock exclusion under sec. 1202, I.R.C., deductions for uncollected software development invoices under sec. 165, I.R.C., as business losses or, alternatively, under sec. 166, I.R.C., as bad debt losses, and deductions for meals and entertainment, advertisement, rent, and utilities expenses under sec. 162, I.R.C. Held: P may not claim a sec. 1202, I.R.C., qualified business stock exclusion to shield from tax any part of the proceeds from the…

1Opinion of the Court

SIVATHARAN NATKUNANATHAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Natkunanathan v. Comm'r

No. 17291-07

United States Tax Court

T.C. Memo 2010-15; 2010 Tax Ct. Memo LEXIS 17; 99 T.C.M. (CCH) 1071;

February 1, 2010, Filed

R determined a deficiency and an addition to tax under sec. 6651(a)(1), I.R.C., for failure to file on time. In response, P claimed a qualified business stock exclusion under sec. 1202, I.R.C., deductions for uncollected software development invoices under sec. 165, I.R.C., as business losses or, alternatively, under sec. 166, I.R.C., as bad debt losses, and…

2Cases cited20 opinions

  1. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  2. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  3. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  4. Lucas v. EarlSupreme Court of the United States · 1930
  5. Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992

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3Cited by1 opinion

  1. Natkunanathan v. CommissionerUnited States Tax Court · 2015

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